Torts; Whether Court Properly Found that Plaintiff's Malicious Prosecution
and Emotional Distress Claims Failed Because There was Probable Cause for her
Arrest; Whether Doctrine of Qualified Immunity Barred § 1983 Claims; Whether Doctrine
of Governmental Immunity Barred Negligent Supervision Claim. The plaintiff,
an African-American female, discovered that the septic system to her Bloomfield home was leaking into her yard. Her neighbor, James Matthews, a Caucasian male,
was experiencing a similar problem. The West Hartford/Bloomfield health district
(health district) later received a complaint regarding the plaintiff's yard. Daniel
Sweeney, a health district employee, directed the plaintiff to repair her
septic system within a specific time period. When the plaintiff failed to make
the necessary repairs, Sweeney applied for a warrant for her arrest based on
her violations of state and local health codes. The plaintiff was arrested,
and the charges against her were ultimately nolled. She then brought this
action, asserting claims of malicious prosecution and intentional and negligent
infliction of emotional distress against Sweeney and a claim of negligent
supervision against Sweeney's supervisor, Steven Huleatt. She also sought
relief under 42 U.S.C. § 1983, alleging that Sweeney and Huleatt treated her
differently than Matthews based on her race and gender, thereby depriving her
of her right not to have laws selectively enforced against her. Finally, she brought
direct liability claims against the towns of West Hartford and Bloomfield under General Statutes § 52-227n and sought indemnification from the towns under
General Statutes § 7-465 for the improper acts of their employees. The trial
court granted summary judgment in favor of the defendants on all counts. It
found that the malicious prosecution claim failed because the facts known to
Sweeney when he applied for the arrest warrant supported a finding of probable
cause to believe that the plaintiff would not comply with the health district's
order. As to the emotional distress claims, it found that subjecting a
government employee to litigation for infliction of emotional distress arising
from a valid arrest warrant would be contrary to public policy and inhibit the
enforcement of the law. It also found that the doctrine of qualified immunity
barred the § 1983 claims because it was objectively reasonable for Sweeney and
Huleatt to believe that their actions did not violate the plaintiff's equal
protection rights. It stated that the evidence did not show that Sweeney knew Matthews
was Caucasian and that no formal complaints had been lodged against Matthews.
Moreover, it found that Huleatt was entitled to governmental immunity on the
negligent supervision claim because the allegations against him involved
discretionary acts. It also stated that the "identifiable person-imminent
harm" exception to governmental immunity did not apply because any harm that
the plaintiff could have been subjected to, as a result of Sweeney's or
Huleatt's conduct, was not imminent. Finally, it determined that the claims
against the towns failed because they were derivative of the claims against
Sweeney and Huleatt. In this appeal, the Supreme Court will decide whether the
trial court properly granted summary judgment in favor of the defendants.